Privacy Policy

Effective date: September 28, 2026

1. Who this policy covers

This Privacy Policy applies to the Twinkle mobile application, website, payment flows, and related services (together, the “Service”). “Twinkle”, “we”, “us”, and “our” mean the operator of the Service. “You” means the person using it. The Service is for people aged 18 and older.

For privacy questions, access, correction, deletion, or complaints, contact jw.nyaguthii@gmail.com.

2. Information we collect

2.1 Account and identity information

When you create or use an account, we may collect your name, email address, phone number, Firebase account identifier, password authentication record, profile completion state, and account timestamps. We do not store your plain-text password.

2.2 Profile and discovery information

You choose whether to provide age, gender, pronouns, biography, introduction, interests, relationship goals, lifestyle information, preferences, discovery distance, country, photos, and other profile details. Profile information and photos are displayed to other members as described in the app so that discovery and connections can work.

2.3 Location information

If you grant device permission, we may receive location information to support nearby discovery and calculate an approximate distance. We aim to show other members an approximate distance and country rather than your exact location. You can deny or revoke device location permission, although nearby discovery may not work correctly without it.

2.4 Activity and safety information

We collect likes, dislikes, swipes, mutual connections, profile views, matches, messages, reports, blocks, unmatches, presence or last-seen timestamps, notification preferences, subscription entitlements, payment references, and related timestamps. We use this information to provide features, enforce free and paid limits, prevent abuse, and keep records of safety actions.

2.5 Device and technical information

We may receive device or app information such as push-notification tokens, app version, operating system, crash and diagnostic logs, approximate network information, and security events. Firebase services may process technical and usage information for authentication, hosting, database, file storage, messaging, monitoring, and reliability.

2.6 Payment information

When you buy a Twinkle product, we receive the Paystack transaction reference, amount, currency, product, payment status, customer identifier where supplied, and subscription start or expiry information. Paystack handles card or other payment credentials. Twinkle does not store your full card number or card security code.

3. How we use information

• Provide the Service: create and secure accounts, display profiles, calculate discovery results, process likes and connections, deliver messages, and show your own profile.
• Provide payments: initialise and verify Paystack transactions, record paid entitlements, apply subscription expiry, resolve failed or disputed payments, and provide support.
• Safety and integrity: enforce age and account rules, investigate reports, block reciprocal visibility, detect fraud or abuse, protect members, and comply with lawful requests.
• Communications: send security, service, connection, message, payment, and policy notifications when appropriate and permitted.
• Improve the Service: troubleshoot, measure reliability, understand feature use, and improve matching and user experience using aggregated or de-identified information where practical.
• Legal and business purposes: comply with law, maintain records, resolve disputes, enforce our Terms, and protect rights, property, and safety.

4. Legal bases and choices

Depending on the context, we process information because it is needed to perform our contract with you, because you consented, because we have a legitimate interest in operating a safe and reliable dating service, or because the law requires it. You may withdraw optional consent or turn off optional notifications and location permission. Withdrawing consent or permissions may prevent a feature from working and does not invalidate processing already carried out lawfully.

5. What other members can see

Twinkle is a discovery service. Other members may see the profile details, photos, interests, approximate distance and country, activity indicator, likes or connection state, and messages that you choose to make available through the Service. They do not receive your password, payment credentials, private account fields, or exact device location through a normal profile. Do not publish information you want to keep private.

6. When we share information

We share only what is reasonably needed for the purposes in this policy:

• Firebase and Google Cloud: authentication, Firestore database, Cloud Storage, Cloud Functions, hosting, push messaging, security, and operational infrastructure.
• Paystack and payment providers: payment initiation, verification, settlement, fraud checks, customer support, and payment records. Paystack processes payment details under its own policies and terms.
• Service providers: vendors that host, secure, monitor, support, or maintain parts of the Service under confidentiality and processing obligations.
• Other members: profile and interaction information that the Service is designed to display, as described above.
• Authorities and advisers: regulators, law enforcement, courts, professional advisers, or other recipients where disclosure is required by law or reasonably necessary to protect people, investigate abuse, enforce rights, or complete a business transfer.

We do not sell your personal information as a data-broker product. We do not give advertisers your private messages or full payment credentials.

7. International processing

Firebase, Google Cloud, Paystack, and service providers may process information in countries other than the country where you live. We use the providers and safeguards available to us, limit access to what is needed, and require appropriate security and confidentiality commitments where applicable.

8. Retention and deletion

We retain account and profile information while your account is active. We retain transaction and payment records for as long as needed for accounting, tax, fraud prevention, disputes, and legal obligations. Safety reports, blocks, and related records may be retained to protect members and prevent repeat abuse. Backups may take additional time to expire.

You can start account deletion from Settings → Delete account in the Twinkle app. You may also request deletion by emailing jw.nyaguthii@gmail.com from your account email or by providing enough information for us to verify ownership. We will verify the request, delete or anonymise information that we no longer need, and retain only what is required by law or legitimate safety and dispute purposes. Deleting an account may end access to unpaid features and does not reverse a completed payment unless a refund is separately approved.

9. Your rights

Subject to applicable law and reasonable identity verification, you may request access to personal information we hold about you, correction of inaccurate information, deletion, a copy in a usable format, restriction or objection to certain processing, and withdrawal of consent. You may also complain to the relevant data-protection authority. In Kenya, you may contact the Office of the Data Protection Commissioner (ODPC) if you believe your rights under the Data Protection Act have not been respected. Contact us first so we can investigate and resolve the request.

10. Security

We use access controls, authentication, security rules, verification workflows, encryption in transit where provided by our infrastructure, and operational monitoring intended to protect information. No internet service is completely secure. If you suspect an account or security issue, contact us promptly and change credentials that may be exposed.

11. Children

Twinkle is not for anyone under 18. We do not knowingly create or maintain an account for a child. Twinkle prohibits child sexual abuse and exploitation, grooming, sexual solicitation of a minor, and CSAM. If you believe a child has provided information or is at risk, report the account in the app or contact the designated child-safety team through our Child Safety Standards page so we can investigate and remove it where appropriate.

12. Notifications, links, and third parties

You can manage push notifications through Twinkle and your device settings. Twinkle may contain links or integrations operated by third parties, including Paystack. Their privacy policies and terms govern their services. We are not responsible for third-party practices outside our control.

13. Policy changes

We may update this policy when our data practices, Service, or legal obligations change. We will publish the new version with a new effective date and provide additional notice or request consent where required. Continued use after the effective date means the updated policy applies to future processing.

14. Contact

For privacy questions, rights requests, deletion requests, payment records, or complaints, email jw.nyaguthii@gmail.com. Please do not include a full card number or card security code in an email.